United States Supreme Court Rules Prison Inmates Not Entitled To Miranda Warnings

Posted By
Akron Criminal Defense Attorney

Tuesday, the United States Supreme Court issued a ruling stating that investigators are not required to advise prison inmates of their Miranda rights prior to conducting jailhouse interrogations regarding crimes unrelated to offense underlying the current incarceration. In
Howe v. Fields, Slip Opinion No. 10–680, the Court voted 6-3 to overturn a
6th Circuit Court of Appealsdecision throwing out the confession and conviction of Randall Lee Fields.

While serving a 45-day prison sentence, Fields confessed to sexually assaulting a minor during an interrogation by prison officials and local sheriff's deputies. During the interrogation, Fields was placed in a conference room and advised several times that was free to leave at any time, however, after seven hours of questioning, Fields eventually confessed and was charged and convicted of criminal sexual assault.

Writing for the majority, Justice Samuel Alito opined, "Imprisonment alone is not enough to create a custodial situation within the meaning of Miranda." Alito reasoned that questioning an inmate doesn't bring the "shock" of arrest that free people experience and the coercive pressure that follows. Further, Alito concluded, an inmate has no expectation of a quick release and there is no chance of a lighter sentence or any type of reprisal for not talking .

Dissenting Justice Ruth Bader Ginsburg stated, "Today, for people already in prison, the court finds it adequate for the police to say: `You are free to terminate this interrogation and return to your cell.' Such a statement is no substitute for one ensuring that an individual is aware of his rights."

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